BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

113. In Ashish Agarwal (supra), this Court allowed the assesses to avail all the defences, including the defence of expiry of the time limit specified under section 149(1). In the instant appeals, the reassessment

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), HYDERABAD vs. SEW INFRASTRUCTURE LIMITED, HYDERABAD

Bench: Justice (Retd.) C.V. Bhadang, Shri Mahavir Singh & Shri G. Manjunatha

reassessment proceedings under Section 147 of the Act are for the benefit of the Revenue, and hence, no new claim can be raised towards any deduction or expenditure in the :4: ITA Nos. 1717 to 1720/Hyd/2017 & return of income filed in response to Section 153A of the Act. The AO further held that the appellant is not entitled

SHARATH KUMAR REDDY SAREDDY,WANAPARTHY, MAHABUB NAGAR. vs. INCOME TAX OFFICER, WARD -1, MAHABUBNAGAR

In the result, appeal filed by the assessee is dismissed

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1096/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2022-23) Shri Sharath Kumar Reddy Vs. Income Tax Officer Sareddy, Wanaparthy Ward – 1 Mahbubnagar Mahbubnagar Pan:Hpwps0712H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.A. Sai Prasad, Ca राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 16/07/2025 घोषणा की तारीख/Pronouncement: 20/08/2025 आदेश/Order

reassessment unless a provision to that effect inserted by amendment is either expressly or by necessary implication retrospective. CED v. M.A. Merchant 1989 Supp (1) SCC 499. We would also like to reproduce hereunder the following observations made by this Court in the case of Govinddas v. ITO [1978] 103 ITR 123, while holding Section 171 (6) of the Income

EXPRESSWAY SERVICES PRIVATE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeals filed by the assessee in ITA Nos

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 22. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the searched person and other associated persons/entities, but separate panchanama was drawn

EXPRESSWAY SERVICES PVT LTD,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, the appeals filed by the assessee in ITA Nos

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 22. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the searched person and other associated persons/entities, but separate panchanama was drawn

EXPRESSWAY SERVICES PVT LTD,HYDERABAD vs. DCIT., CENTRAL CIRCLE -2(4), HYDERABAD

In the result, the appeals filed by the assessee in ITA Nos

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 22. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the searched person and other associated persons/entities, but separate panchanama was drawn

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

ACIT., CENTRAL CIRCLE-2(4), HYDERABAD vs. PRATHIMA INFRASTRUCTURE LIMITED, HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

PRATHIMA INFRASTRUCTURE LIMITED,HYDERABAD vs. DCIT., CENTRAL CIRCLE-2(4), HYDERABAD

In the result, appeals filed by the Revenue are dismissed

reassessment, as explained under Section 292CC and the limitation provided under Section 153B of the Income Tax Act, 1961. 19. In the present case, there is no dispute with regard to the fact that, although the joint warrant of authorization was issued in the name of the assessee and other associated persons/entities, but separate panchanama was drawn in the case

WESTERN UP TOLLWAY LIMITED,NOIDA vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the appeals of the assessees are allowed in terms of our aforesaid observations

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Tp Nos.67/Hyd/2022 & 493/Hyd/2022 (िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19) M/S Western Up Tollway Vs. Deputy Commissioner Of Limited, New Delhi Income Tax, Circle 8(1) Pan:Aaacw6002B Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita Tp No. 170/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) M/S Mahua Bharatpur Vs. Deputy Commissioner Of Expressways Ltd, Income Tax, Circle 5(1) Hyderabad Hyderabad Pan:Aaecm4426F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocates Ajay Vohra & Ananya Kapoor राज" व "ारा/Revenue By:: Smt. U. Mini Chandran, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 09/12/2025 घोषणा की तारीख/Pronouncement: 12/12/2025 आदेश/Order Per Bench: These Three Appeals Are Filed By M/S. Western Up Tollway Ltd (2) & Mahua Bharatpur Expressways Ltd (1) (“The Page 1 Of 38

reassessment cannot be read into Section 144C more particularly when the provisions of Section 153 are excluded by the non-obstante clause in section 144C(13) and hence the proceedings are not barred by limitation. Per contra, it has been contended by the learned senior counsels appearing for the respondent(s)/assessees that the outer time limit under Section